Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
ITAT held that set-off of permanent establishment (PE) loss against interest income is permissible under the tax treaty. The tribunal interpreted Article 11(2) as allowing computation of income per domestic law provisions, enabling inter-head loss adjustment. The assessee's claim of set-off was deemed valid, with the tribunal emphasizing that "gross" interest refers to income without expense deductions. Additionally, the tribunal recognized the alternative claim under Section 115A(1)(a)(iiaa), finding the external commercial borrowing (ECB) loans compliant with RBI regulations, thus qualifying for a concessional tax rate of 5% with applicable cess and surcharge.
ITAT held that set-off of permanent establishment (PE) loss against interest income is permissible under the tax treaty. The tribunal interpreted Article 11(2) as allowing computation of income per domestic law provisions, enabling inter-head loss adjustment. The assessee's claim of set-off was deemed valid, with the tribunal emphasizing that "gross" interest refers to income without expense deductions. Additionally, the tribunal recognized the alternative claim under Section 115A(1)(a)(iiaa), finding the external commercial borrowing (ECB) loans compliant with RBI regulations, thus qualifying for a concessional tax rate of 5% with applicable cess and surcharge.
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